Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
WHO WE ARE
SCMPrivate LLP is an investment firm authorised and regulated by the Financial Services Authority and operates a data controller function. The operational address is:
81 Fulham Road
London SW3 6RD
Our nominated representative is Barnaby Barker and he can be contacted at firstname.lastname@example.org
INFORMATION WE COLLECT
In the course of running and maintaining our website we collect and process the following data:
- Information about your use of our site, including pages viewed and the resources, links and PDFs you access. Such information includes traffic data, device data, location data and other communication data;
- Information provided voluntarily by you. For example, your email address when you register to receive information; and
- Information that you provide when you communicate with us via the Contact Form.
We may also collect and process the following data about you when providing services to you:
Personal information provided during the account opening process;
- Information provided by you which relates to other individuals related to your account;
- A record of any correspondence or communications between us; and
- Details of transactions we carry out on your behalf.
Under the GDPR Directive, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.
We will only process your personal data ;
f at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
HOW WE USE THE DATA WE COLLECT
We use information about you to:
- To establish and administer accounts you set up with us and to fulfill the terms of any agreement you have with us;
- Present site content effectively to you;
- Provide information, products and services that you request, or (with your consent) which we think may interest you;
- To notify you of any changes to our services, products;
- Allow you to use our interactive services if you want to; and
- Tell you our charges.
- Provide data analysis for our management team.
If you are already our customer, we will only contact you electronically about products and service that pertain to your original investment.
If you are a new customer, you will only be contacted if you agree to it.
If you don’t want to be contacted for marketing purposes, please let us know.
In addition, if you don’t want us to use your personal data for any of the other reasons set out above, you can let us know at any time by contacting us at email@example.com, and we will delete your data from our systems. However, you acknowledge that doing so will limit our ability to provide the best possible services to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
WHERE WE STORE YOUR DATA
In operating our SCM Direct website it may become necessary to transfer data that we collect from you to locations outside of the EEA for processing and storing. By providing your personal data to us, you expressly consent to this transfer, processing or storing. This may involve the transfer of data by electronic media including the internet. Where your data is transferred outside of the UK, SCM Private will ensure that the recipient agrees to keep your information confidential and hold it securely in accordance with the requirements of GDPR.
We only keep your personal data for as long as we need to in order to use it as described above, and/or for as long as we have your permission to keep it. In any event, we will conduct an [annual] review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
DISCLOSING YOUR INFORMATION
- Where we are legally required by law to disclose your personal information.
- To further fraud protection and reduce the risk of fraud.
- In the event that we sell any or all of our business, your personal information will be disclosed to the buyer.
We have in place procedures and controls to protect the personal data we collect from you from loss, misuse, unauthorised access, disclosure, alteration and destruction in accordance with GDPR.
You should protect access to your online account by keeping your username and password private and ensuring you log off after using a shared computer.
You can ask us not to use your data for marketing by contacting us at any time at firstname.lastname@example.org.
Under the GDPR, you have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling as set out below.
LINKS TO OTHER SITES
QUALITY OF INFORMATION
We till take all reasonable efforts to ensure that any personal information which we collect from you is accurate, up-to-date and complete. If any of the information you have previously provided to us changes or is no longer accurate please notify us at email@example.com.